United States District Court, D. Colorado
STEPHEN D. BELL DORSEY & WHITNEY LLP, KRISTIN K. ZINSMASTER DORSEY & WHITNEY LLP ATTORNEYS FOR DEFENDANTS QUANTA FIELD SERVICES, INC. AND QUANTA POWER, INC.
MARI NEWMAN DAROLD W. KILLMER CASEY ROSE DENSON KILLMER, LANE & NEWMAN, LLP, MARCEL A. QUINN ATTORNEYS FOR PLAINTIFF ANDREW TECHMANSKI
STIPULATED PROTECTIVE ORDER CONCERNING CONFIDENTIAL INFORMATION
Plaintiff, Andrew Techmanski ("Plaintiff), and Defendants Quanta Field Services, Inc. and Quanta Power, Inc. (together, "Quanta" or "Defendants") (collectively, the "Parties"), through their undersigned counsel, stipulate as follows for an order, pursuant to Federal Rule of Civil Procedure 26(c), that confidential information be disclosed only in the designated ways:
1. As used in this Protective Order, these terms have the following meanings:
a. "Action" means the case styled Andrew Techmanski v. Quanta Field Services, Inc. and Quanta Power, Inc. Case No. 15-CV-02432- DME-MJW, in the United States District Court for the District of Colorado.
b. "Attorneys" means in-house counsel, and outside counsel of record representing or advising a Party in the Action.
c. "Documents" are all materials within the scope of Fed.R.Civ.P. 34.
d. "Confidential" Documents are Documents designated pursuant to paragraph 2, below.
e. "Party" or "Parties" means the Plaintiff and Defendants in this action.
f. "Written Notification" and/or "Notice to Counsel" as required under the terms of this Protective Order shall with respect to Plaintiff require that such notice be delivered to: Marcel A. Quinn, Hammer & Quinn, PLLC: 100 Financial Drive, Suite 100 P.O. Box 7310, Kalispell, MX 59904-0310, email@example.com, and Mari Newman, Killmer, Lane & Newman, LLP, 1543 Champa Street, Suite 400 Denver, CO 80202, firstname.lastname@example.org; and with respect to Defendants, to Stephen D. Bell, Dorsey & Whitney LLP, 1400 Wewatta Street, Suite 400, Denver, Colorado, 80202, email@example.com.
g. "Written Assurance" means an executed Document in the form attached hereto as Exhibit A.
2. A Party may designate a Document (including interrogatory responses, other discovery responses, and transcripts) "Confidential" to protect information within the scope of Fed.R.Civ.P. 26(c)(1)(G) where the designating Party in good faith believes the Document contains confidential, financial, medical, proprietary, or commercially sensitive information. A Document shall not be designated Confidential where the Document shows on its face to have been disseminated to the public. Documents shall be designated Confidential at or prior to the time of production of the documents by stamping or otherwise marking the documents as Confidential on each page of the document to be deemed confidential, or, in the case of depositions, as provided in paragraph 10 below. A Party may designate Documents produced in an electronic format as Confidential by placing a confidentiality marking on the disk or device on which the Documents are produced.
3. A Party receiving Documents designated Confidential may object to that designation and request the removal of such designation as outlined under the procedures set forth under paragraph 14 of this Protective Order.
4. All Confidential Documents, along with the information contained in those Documents, shall be used solely for the purpose of this Action and no other separate proceeding of any kind. No Party receiving such Documents shall, directly or indirectly, use, transfer, disclose, publicize, promote, or communicate in any way the Documents or their contents to any person other than those specified in paragraphs 5 or 6 of ...